G2. Business ethics and compliance Enphase Code of Conduct We hold ourselves to operating under the highest ethical standards and believe that all people should be treated with dignity and respect. The Enphase Code of Conduct applies to all o昀케cers, directors and employees, contractors, and consultants. It sets forth guidelines to ensure proper and ethical behavior, legal compliance, and adherence to our standards, policies, and procedures. We are committed to complying with all applicable laws and regulations everywhere we operate. “We hold ourselves to operating Supplier Code of Conduct under the highest ethical We choose business partners who share our mission and intend to work only with those standards and believe that all suppliers who agree that our shared success is based on acting ethically and lawfully. We people should be treated with expect our business partners to adhere to our Supplier Code of Conduct, which includes dignity and respect.” (a) conducting business with high ethical standards; (b) complying with applicable laws; (c) supporting the human rights of workers and treating their employees with dignity; (d) adhering to anti-slavery and human tra昀케cking principles; and (e) maintaining safe and healthy working conditions. Compliance training To meet legal requirements and regulations, such as anti-discrimination laws, health and safety regulations, and data privacy laws, we o昀昀er a set of compliance trainings, with an objective to provide required information and awareness to all employees, including managers, on anti-corruption, bribery, human tra昀케cking and slavery, safety, code of conduct, workplace harassment prevention, ISO training and more. We achieved 100% completion of our required compliance courses and had no con昀椀rmed cases of breaches to our Code of Conduct in 2023. Clawback policy E昀昀ective October 2, 2023, the Compensation Committee approved a new Executive Compensation Clawback Policy (the “Required Clawback Policy”), which is designed to comply with, and will be interpreted in a manner consistent with, Section 10D of the Exchange Act and the applicable Nasdaq rules. In addition, we also maintain clawback provisions that apply to employees, including our named executive o昀케cers, that receive equity awards under our 2023 Performance Share Program that allows the Board to recover any incentive-based compensation that was paid based on erroneous 昀椀nancial information reported under securities laws (“PSP Clawback Provisions”). For additional information regarding the Required Clawback Policy and the PSP Clawback Provisions, please refer to our 2024 Proxy Statement. ENVIRONMENTAL, SOCIAL, AND GOVERNANCE REPORT 2023 77
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